Document mpRmJwD0X5Xx9Lpja6XOeYaxO
, FRXCTlCtt MATERIALS ST/u3iA?BS XHST1T8TS, IhC., E. 210 EOBTE 4, FAWUS, K.J.
07652
MTOTTES 0? THE KEBtUW
of Che (
ASBESTOS STUDT CagtTrTSZ
Friday, June 1, 1973, at 9:30 A.H. at the
Institute Office* E. 210 Route 4, Parama, S.J.
MEMBERS PRESENT
I. E. Weaver, Chairman H. Wagner E. H. Feierabcud
OTHERS gRESEST
S. B. McGinnis (for J. C. Henning) H. Jack (for W. Spurgeon) D. E. Scone R. C. Wyatt W. B. Gustafson S. if. 2>ris2aa*
ttSBERS HOT PRESENT
J. C. Henning T. BU V. Spurgeon
Tbe meeting waa called Co order by
fcaybestoa^Kaohattaa, lac Carlisle Corporation Abas Corporation
PLAINTIFFS EXHIBIT
WV-06030
World Beetoe Company Send!* Corporation Bendlae Corporation Mareaoat Corporation Karemont Corporation Friction Materials -Standard loadtuts, Inc.
World Bentos Company S. K. Porter Co. Bendiz Corporation
. Weaver, Chairman, at 9:39 .K.
HZK0T8S OF gamoos MEETING
The Secretary reed e eumnary of the Minutes of the Meeting held Fernery IB, 1973, These minutes had bean released and a notion for cheir acceptance had been obtained*
Upon notion duly oade, seconded end unanimously passed. It was
RESOLVED: To accept the minutes of Che February 15, 1973 meeting as distributed.
LABELING
P-F MSI-
. . tv.
k
0007
At the February Id, 1973 meeting, the Secretary was directed to distribute information on typical CAUTION libels now In use. The purpose of this diatribe
tion wes so that the CovoriLteae Matters could review what is available and would be is a position to prepose label specifications to meet tbe QSBA requirement*.
One Better suggested Apr the else of tha labeling used should be of sufficient sire to be noticeable as larce carton and ttould be muBiimirdily ttHer ttr
WV-06030
Minutes o the Aebroto* Study Commute* Meeting
2- -
June 1, 2973
still noticeable OB Smaller package. 6m m>bet vai using tt insert with
CAOTCR label tufted Into the package. The use of irprioted CAETICH labels
on the carton is desirable because -it is essentially a ooe-tine tooUna eost.
The use of separate label*:is a continuing added direct expense. , hose weabezv
new using separate gunned-labels will eventually go over to^^japtintiagitbe^. v....i carton when ordered, * tj&VSU
.: - '?
* .'f--s*;'*
' -"?**rf?
In vfeat east be a response or a reaction by other*,-many custoaere are nos
.
asking Mashers about bow such percentre of asbestos ~is in the brake miningsV>^r
This could be a reaction os Che customer's part as to whether they would heve _-l :
to put control practloea in their factories because of the asbestos that la *
contained in brake lining* To east the true spirit of the OSHA regulations#' i . ..
manufacturers doing si&sequent drilling# grinding or euCtisg of asbestos contain--
fag brake nwfwgy should care the care; that OSSA suggests.
One neuber felt that where he vs* shipping drilled ground lining eats that be . ; would not base to isprlat these snail cartons with the OSOA C&tTTICfK label. Other --* ushers are eisply putting-die OSSA CA27TIOiJ labeling on everything. When it was suggested that the Corolttee should take a position on this labeling requlreoent, the seekers of the Ccnsittee were referred back to the Basolution that was Bade an February 26, 1973. thi* SeaalutioB said, .in affeet# that OSHA labeling practices should be adhered to where asbestos containing Bstexlals do sot have ^ asbestos fiber completely locked in or where subsequent operations merg be performed. The question concerning the drilled and ground set 1st While it is unlikely thee subsequent operations will be performed, is it possible that they aey be performed?
After a lengthy discussion it was decided Chat no resolution concerning recontw^nried CADTIO0 label* would be proposed. Bather# the Secretary is directed to send to the Kufcership copies of typical labels now in use.
It was called to the Secretary** attention that bis yellow Bulletin of March 30, 1973 was in error, la thee settee it stated, "Avoid breathing dust". The wordr ing should bsve been# "Avoid erastine dust". This error will be called to the attention of the Membership.
The Chairman brought up another point as regards labels. There is a sign that cm be peeted in the factory where there are restrictions cobcorning asbestos dust la -the vtaespbere. This As 'a~eean4asd .sign Jor .placing in the factory which says: "C4BTCGN - Asbestos dust hazard; avoid breathing dust; was assigned protective equipment; do not reasis in area unless your work requires it; breathing asbestos dust any be hazardous to your health". Information on the availability of these signs will be sent to the MeTOership.
EPA EMISSIONS STANDARDS FOR ASBSTOS
While the new EPA eaaetons standarda appear to be reasonable# there is soae difficulty is interpretation. For example, the standards are not siaply "So visible erosions" but (2) if the control equipment does not oeet the air clean ing zequireronte in the regulations# so visible eaissiose are permUsibla, or (2) one could even have visible emissions if they were using a collector with the specifications * receoended by the ?A* Za other words# if you hero the S3A*e recenended collector you could possibly have visible emissions end still be cooplying with the. EPA requirements. It goes without saying, that interpre tative of the requirements by Individuals in the different EPA regions nay vary quit* a bit.
Minute* of the Asbestos Study Comlttee Meeting .
-3-
Jug* 1, 1973
m tte dry-bs* collector. * re EPA Baf om.iTrtit Officer rent * vmper free sh*
tuck where t vet collector It
the-aource best be able to prove there it no
asbestos being aitcharged. In other words. It can be inferred that If e source
has wet collectors they nay sere likely be cited for visible emissions.
While It it apparent that* the tPlfi esLaeloBS standards promote the dry cnllee- tion of asbestos la bags, ware? -problems have beenindicated with these collectors* One of dte problems wee repeated fires in the collection system.* Another mesber . stated that be too bad this problem until cigarette smoking was banned An tbs -* factory. Since discontinuing sacking in the' factory, be claims they have net '
had Mrs Chao oss or two firms In tbs lest 15 years* Another member said that may be, but they have bad a Wo Swkiflg tula for many years end they still base fires. Ibis party blasts the Hres on the incentive program where the workers receive a bonus for exceeding certain work standard*. Ibis promotes the taking of heavier cuts with grinding wheels amd creates sparks whleh apparently promote the fires in the system. The operation that has not bad any fires for the past ~ 25 years does not have an incentive system and does not permit smoking in the work plate. Where the wet collectors are now in use, apparently the EPA la permitting their use eg complying with the requirements.
At this point, the disposal of the materials picked up by the collectors was brought up. One mereer sent the dust to a pelletising machine* Xa this process they add 5X~1QX cement to the pelletiser. A volume redaction In the order of 5 to J was developed, the pellets ere taken by truck mod dumped as land fill. While the pellets could be broken down into a powder, If they receive reasonable handling they can be readily moved from the pei.letiring machine to the lend fill operation. Zt is this mesher'a intention to install e vacuum system from the collecting areas to go to e central pellstiring machine. One member deecxlbed his handling of dust from <l) A central collector, to C2) a screw conveyor, re (3) a truck, and to (4) the land fill. The workers in this case use respirators.
The pelletizing operation not only reduces the transportation cost by three tinea hue eliminates the need for e watering truck end an individual to vet down the land fill. However, the costa of this pelletizing equipment are substantial. A manufacturer of peilatiring equipment la Ferro Tech Inc., 1231 Banksvilla Bead, Pittsburgh, Pa. 15216.
Several members mentioned that in dealing with the SPA Beglonal Office# they were .having difficulties deciding what was a "new source" and what was an "existing source". Also, where one manufacturer adds one machine to an e*lsttng,'tia*on system be msy nee be in co^llance without getting a Waiver of Compliance. Appar ently the EPA will not give a Waiver of Compliance disc will take more Chao IP months to complete, A* applicant must give the steps to be taken and the schedule to be met. When each date arrives, the applicant must advise EPA concerning
eospledan of that stage of the schedule.
One member felt that we should review the EPA source report *ot _fftt e better
understanding of whet they were
for. rapt one of the report would be used
for each factory. As these would most likely b* several points of emission, page
2 would be completed for each stack, or collector that emits asbestos.
Xf a manufacturer wished to make an addition or modification in bis plant with equipment that might put asbestos Into the atmosphere, he must file with the EPA. On pegs 1 of the report be would cross off the words "Source Import" and type la either "Application to Construct s Hew Source", or "Application to Modify Exist ing Source". In reviewing page 2 of the report vndtr "Process Description**, earns questions care up as to hew to complete this section. One aether who bed warned on this repo** with the EPA esid jam eboold retar bar* (he rygw-yrf-
Minute* of the' Asbestos Send? Cosndctee Heeties'
June 1, 1973
neehlnery msed without quaetifyiag. Another mtrfaer indicated that the EPA Insisted that he list tine type of equipment end the nushers of each piece of equipment. If the SPA specifically said to list the lumbers and types of equip* aeat Is this section It wea suggested thst they would have said so on page 2 of the report. The question of putting down the ambers aad types of equipment could become very aafeersome where s manufacturer wished to move a grinding machine v froo a location vlth tone collector, to smother location where it would be hooked -
into another collector. Y The seiner who filed with'the.SPA worked on reports In v.
2 different Jurisdictions: - New fork sad Tennessee.? Be indicated that at neither location did he enter the nuafeer of pieces of eqtdpaent on this form. ? (Since thd meeting he called to advise that the application filed in Tennessee without quantities was accepted by .the EPA. Bis application in Hev York State had not been either accepted or rejected as of June 4, 2971.) It would appear that Regional Offices are not in agreement as regards quantification of the equipment under the "Freeses Description."
The question came up concerning interpretation of question 3, the "Amount of Pollutant.tt In meay factories a set of dry six brake blocks could emit into a collection aystea at the minerat the briquette press, st the cut-off wheels, at grinding, at drilling,, sad at inspection and boxing. The problea is that this Is the eaas original asbestos vhieh entered the process sad might be cotated 6-8 times. So. in effect, e factory taking in one Billion pounds of MbeBtM/^ViSlo,rd2iBStP?^e?loSa^I^. *.* *"
appear chef eijSie aiton pounds of asbestos is going Into the operadoc. From the wording of the form, it would appear that this is exactly what the SPA vents. However, another aether vas told that this in not what the EPA Wants. He suggests that if a factory takes in one million pounds of asbestos into the process that it should not report is total more than one elHIon pounds of asbestos. If he had 20 different emission points, he would divide the one mi111as pounds of asbestos by 20 to give the "amount of pollutant.** Again, their apparently has been a difference in interpretation from different Regional Offices of the SPA.
Os page 3 of the report, under "Waiver of Compliance," it was stated that Sections
2a and 2b did not have to be completed unless EPA specifically requests this information.
INSTITUTE SDCAAt OH SAFETY AND HSAUB
ttt Yin February 26, 1973 meeting, wuggewtl'O&s were made -(hat -the .Trerlwite consider tbs sponsoring of e seminar for members associated with plant - operations. The Institute indicated it would be willing to sponsor such a Steiner if suffi- . giant interest developed.
A quest!os vas raised as to whether this seminar would apply only to asbestos. The Secretary indicated that such a seminar would apply to any field of interest but it should be related to problems that can be tied into State and Federal regulations. Among the topics suggested for a seminar ware the following:
Air ssapling and asbestos concentration determination. The pulmonary function test aad E-Ray. . Possible extension to include noise and heat stress. Cooperation between vaaageaent and workers in meeting the
regulations Asbestos bag opening machinery.
Hiautee of the Asbeatc* Study Cndttee Meeting
June X, n
lb Secretary vn directed to wake ep a lia* of subjects which igbt t&peg& b ttoership and to eaavas* the meri>ers as regards their interest. Is addition to the agenda items to suggest to the Ifesberahip, it wae suggested that the canvassing letter aak if & individual from that wether* company would attend* where the Meting should be held,; end when the meeting should be held.*-It vss
Uhen the Secretary has prepared a questionnaire it will be submitted to Mr.' -V.** Feederehend for hia review prior to distribution to the Mttdwshlp. - The actual. . agenda will be drafted after the Mahers have Indicated their preference.-~The question was raised as to whether outside speaker* would be involved sad it wee suggested that we were not interested in a eosasrclal pitch at the neeting. Johos-KanviUe had indicated as interest in approaching such a seminar with the idea of promoting their HEAP <fligh Energy dir Filter) pollution control equip* went. It wee suggested that perhaps it night be verZbwfclie Co have nocsidesgrnaks presentations concerning asbestos bag opening equipment,- pelletising, collection, ate* ;Shia will have to be worked out at a future Committee meeting.
Brake and Clntch Fgrf<nq Generated During Vehicle Operation
This particular study vis run by Bendix Research Laboratories under sponsorship of the EFA. A paper vss presented to the S.A.E. by Dr. H. Jacko and Hr. R. DuCharae of Bendix, and Hr. J. Sown of the EFA. The aceual report to the P* is a massive document explaining every test procedure and every method of collection used in the study. A technical paper was presented by these 3 gentlemen at the SAE Meeting in Detroit in Hey, 1973. The study essenially centers on how much ashescos is being put lot* sbe stwspber* from brake lining* and clutch facings. As Dr. Jacko was in charge of this investigation he discussed the paper et our meeting. Be advised that a condensed version appears in Che magazine AUTOMOTIVE EBCrSEESXHG. Among the points chat Dr. Jacko Bade was that there were problems where a brake on ooe side was enclosed and the other brake was open to the regular atmosphere. Modifications had to be Bade involving cooling of the outside of the shroud so diet there would not be too great a ceoparature difference from the left side to die rlt side. This ws more of a preblea with the disc brakes on die fronts. Actually with the necessary cooling, there was hardly any difference between the drus brake rears side to side.
Among Che ite discussed in the paper were how wgefa asbestos dm used in friction wtcritli. It is indicated that there are about 103 million pounds of asbestos in the fzictioo jaacariaJs which are used is Che United States each year. There apparently ere some differences of opinion as regards how such asbestos is Involved but It generally fella in the 90-120 Billion pound range. Actually, the smount subject to wear is about 66-2/32 of the actual lining that gats on to the brake (after grinding), Hben asbestos Is being used in brake linings it is discarded In one of three ways: It gets deposited on the surfaeea of the brake, such as on the caliper, and around the wheel cylinders. (This la surface debris). Additional safarial is collected on the lining surfaces, in the rivet holes, end on Che brake drug. (This Is celled eump debrie) Additional aaeeftal becomes airborne end is collected on methraoe filters. (This Is called airborne debris). It la this latter airborne debris that the research* ere are seeking to quantify.
Baaed on the s^les that were collected, the cexclusions were that sere than 99,71 of the asbestos In the brake lining is converted to other products. By extrapolating the data that they were able to develop on a passenger car the remmerdbeoi indexes that a total of SOSO pends at asbestos 1* pee stBO.'.&m-
Minutes of die Asbestos Stud? Condttee Meeting
4*
June l, 1973
ACMpbiTt*
ashestoe emission Is 3.2S of the total asbestos
emitted free U automotive brake linings and dutch facings la the O.S.
A question arose as to what happens to the asbestos debris that drops out. Ikies It eventually get Into the atmosphere! . It was Indicated Chat baaed on the study of other Materials that apparently, there have, been build-ups each jm -lead along 7
A gentlenaa. fromFord Motor Company was also to present a paper to the AE meeting- '
concerning asbestos particulate emissions into the stmosphexe.'-Bo paper was -<
available at
tins. Theta were some questions concerning procedures sod s
source of dots on the Ford paper, but In soy event the paper indicated a lower -
total asbaatos esission than tbs Bssdlz paper. . These two papers should serve -
e source information when others sre attesting to quantify the asbestos emitted
into the atmosphere from brake linings and clutch fadage.
CISEB ITBS
The topic of OSHA Inspections and enforcement was brought up briefly end the aethers indicated that no new actions had been taken by OSUA as -regards enforce ment concerning the asbestos standards.
The Asbestos Information Association (AIA) is to put out a Ceapliseee Manual concerning control practice. This is still preliminary and there is no advance copy available at this time.
******
There being no further business brought to the attention of the Corns!ttee, tgxa motion duly made and unanimously passed, it was
RESOLVES: to adjourn.
Adjourned: at 2:30 P.H.
2. . Driftlane Secretary
FRICTION MATERIALS STANDARDS INSTITUTE, l'K.t t. 210 ROUTE 4, PARAMUS, N.J. 07652
At
.
UNITES OF THE MEETING
of the
ASSESTOS STUDY COratlTTEE
Friday, June 1, 1973, at 9:30 A.M. ac che
Institute Office, E. 210 Route 4, Faramis, N.J.
MS3GRS PRESENT
I. U. Heaver, Chairman H. Vagner
E. E. Feierabend
Raybes tos-Manhattan, Ioc. Carlisle Corporation
Abex Corporation
others present
S. S, HcCinnis (for J. C. Henning) Si. Jacko (for VT, Spurgeon) D. t. Stone R, C. Wyatt W. H. Gustafson E. W. Urislane
World Bestos Company Eendix Corporation Bendix Corporation Marenont Corporation MarenonC Corporation Friction Materials Standards Institute, Inc.
MEMBERS NOT PRESENT
J, C. Henning T. Sell it. Spurgeon
World Bestos Company G. K. Porter Co. Bandlx Corporation
The meeting was called to order by Mr V?eaver, Chairman, at 9:30 A.M.
misotzs of radios* "ssEnnc
The Secretary read a summary of the Minutes of the Meeting held February 16, 1973. These minutes had been released and a motion for their acceptance had been obtained.
Upon notion duly made, seconded and unanimously passed. It vas
RESOLVED: To accept the minutes of the February 16, 1973 meeting as distributed.
LABELING
At the February 16, 1973 meeting, the Secretary was directed to distribute information on typical CAUTION labels now in vise. The purpose of this distribu tion was so that the Committee ?lechers could review what is available and would b is a position to propose label specifications to *eet the OSSA re^maencs.
Jne orsfee? suggested that the sine of the
us*4 should he of suifTT^aag.
to be noticeable cm a larr* carton end should be terarsamrafaly BssaSerlassL
Minutes of the . Asbestos Study Committee Meeting
-2-
June I, 1973
still noticeable on a smaller package. One member was using an insert with a CAUTION label stuffed Into the package. The use of imprinted CAUTION labels on the carton ia desirable because it ia essentially a one-time tooling cost. The use oi separate labels is a continuing added direct expense, Jlost members now using separate gummed labels will eventually go over to imprinting the carton when ordered.
In what must be a response or a reaction by others, many customers are new asking Members about how much percentage of asbestos is in the brake linings. This could be a reaction on the customer's part as to whether they would have to put control practices in their factories because of the asbestos that is contained in brake lining. To meet the true spirit of the OSKA regulations, manufacturers doing subsequent drilling, grinding or cutting of asbestos contain ing brake linings should use the care that OSILA suggests.
One member felt that where he was shipping drilled ground lining sets that he would not have to imprint these small cartons with the OSHA CAUTION label. Other members are simply putting the OSHA CAUTION labeling on everything. When it was suggested that the Committee should take a position on this labeling requirement, the members of the Com!tree were referred back to Che Resolution chat vas made on February 16, 1973. This Resolution said, in effect, that OSHA labeling practices should be adhered to where asbestos containing materials do not have asbestos fiber completely locked in or where subsequent operations nay be per formed. The question concerning the drilled and ground set is; While It is unlikely that subsequent operations will be performed, is it possible that they may be performed?
After a lengthy discussion it was decided that no resolution concerning recom mended CAUTION labels would be proposed. Rather, the Secretary is directed to send to the Membership copies of typical labels now in use.
It was called to the Secretary's attention that his yellow Bulletin of March 30, 1973 wag in error. Ia that notice it stated, "Avoid breathing dust". The word ing should have been, "Avoid creating dust". This er^or will be called to the attention of the liembership.
The Chairman brought up another point as regards labels. There is a sign that can be posted in the factory where there are -restrictions concerning asbestos dust in the atmosphere. This is a standard sign for placing in the factory which says: "CAUTION - Asbestos dust hazard; avoid breathing dust; wear assigned protective equipment; do not regain in area unless your work requires it; breathing asbestos dust may be hazardous to your health". Information on the availability of these signs will be sent to the Menbcrship.
EPA EMISSIONS STANDARDS FOR ASBESTOS
While Che new EPA erosions standards appear to be reasonable, there is some
difficulty in Interpretation. For example, the standards are not simply "No
visible erosions", but (1) if the control ecuioment does not meet the air clean ing requirements in the reflations, no visible emissions ere permissible, or
<2> one could even have visible emissions If they were using a collector with
the specifications* recommended by the EPA. In other words, if you have the
rpA's reconsended collector you could possibly have visible emissions and still
be eccplyiap with th*.S?A reqnireweats. It soma witiveer: spying, ?*
-P
ration of the requirements by individuals in the different SPA regions may 'vary
quite 9 bit.
Minutes of the .Asbestos Study Commietee Meeting
-3-
June !, 1973
astne dry-bag collector. 2 an EFA Enforcement Officer sees a vspof froo TErE stack -where a wet collector is used, the.source best be 'able to prove there is no asbestos being discharged. In other words, it can be inferred that if a source has wet collectors they nay more likely be cited for visible emissions.
While it is apparent that the. CPA's emissions standards promote-the dry collec tion of asbestos in bags, many problems have been indicated with these collectors. One of the prob lets was repeated fires in the collection system. Another member stated that he too had this problem until cigarette smoking was banned in the factory. Since discontinuing smoking in the factory, he claims they have not had core than one or two fires in the last 25 years. Another member said that may be, but they have had a Wo Stroking rule for many years aDd they still have fires. This party blanes the fires on the incentive program where the workers receive a bonus for exceeding certain, work standards. This promotes the taking of heavier cuts with grinding wheels and creates sparks which apparently promote the fires in the system. The operation that has not had any fires for the past 25 years does not have an incentive system and does not permit sacking in the work place. Where the vet collectors are now in use, apparently the EPA is permitting their use as complying with the requirements.
At this point, the disposal of the materials picked up by the collectors was brought up. One member sent the dust to a pelletizing machine. In this process they add 52-102 cement to the pelletizer. A volume reduction in the order of 3 to 1 was developed. The pellets are taken by truck and dumped as land fill, irnile the pellets could be broken down into a powder, if they receive reasonable handling they can be readily moved from the pelletizing machine to the land fill operation. It is this menber'e intention to install a vacuum system from the collecting areas to go to a central pelletizing machine. One member described his handling of dust from (1) a central collector, to (2) a screw conveyor, to {3} a truck, and to <4) the land fill. The workers in this case use respirators.
The pelletizing operation not only reduces the transportation cost by three times but eliminates the need for a watering truck and an individual to vet down the land fill, bewever, the costs of this pelletizing equipment are substantial. A
manufacturer of pelletizing equipment is Ferro Tech Inc., 1231 Banksville Road, Pittsburgh, Pa. 15216.
Several -members jsaatioaed .that 1a .dealing with the ETA .Regional .Offices -they -were having difficulties deciding what was a "new source" and what was an "existing source". Also, where one raanufsecurer adds one machine to an existing collection system he may not be in compliance without getting a Kaiver of Compliance. Appar ently the EPA will, not give a Waiver of Compliance that will take more than 12 months to coeplete. An applicant oust give the steps to be taken and the schedule to be met. When each date arrives, the applicant oust advise EPA concerning conpletion of that stage of the schedule.
One member felt that we should review the EPA source report fora to get a better understanding of what they were calling for. Page one of the report would be used for* each factory. As there would most likely be several points of emission, page 2 would be completed for each stack or collector that emits asbestos.
If a manufacturer wished to make an addition or modification in his plant with
equipment that might put asbestos into the atmosphere, he must file with the EPA.
On page 1 of the report he would cross off the words "Source Report" and type in
ftramr "splicatics to Construct a Sew Source1*, or "Appli carton to
..ywj-
ttrg Source*. In reviewing page 2 of the report under "Process Description-,
jCToe curstions came up as to how to complete this section. beta
anugitrea on Ais report with the EPA said you should enter here the type
' Minutes of the . Asbestos Study Committee Meeting
-4-
June 1, 19 73
machinery used without Quantifylag. Another z&rber Indicated that the 2A insisted that he Hat the type of equipment and the numbers of each piece of equipr*&rst. If the E?> specifically said to list the nurbers and types of equip ment in this section it was suggested that they would have said so on page 2 of the report. The question of putting dc**n the numbers and types of equipment could become very cumbersome where a manufacturer wished to move a grinding machine from a location with one collector to another location where it would be hooked into another collector. The camber who filed with the EPA worked on reports in 2 different Jurisdictions: 3cw York and Tennessee. He indicated Chat at neither location did he enter the nurber of pieces of equipment on this form. (Since the neeting he called to advise that the application filed in Tennessee without quantities was accepted by the EPA. His application in "ew York State had not been either accepted or rejected aa of June 4, 1973.) It would appear that Regional Offices are not in agreement as regards quantification of the equipment
r under the "Process Description.'5
rue question came up concerning interpretation of question 3, the "Amount of Pollutant." In many factories a set of dry nix brake blocks could emit into a collection system at the mixer, at the briquette press, at the cut-off wheels, at grinding, at drilling, and at inspection and boxing. The problem is that this Is the same original asbestos which entered the process and might be counted 6-S times. So, in effect, a factory taking in one million pounds of asvbest^os/.ccigoointsliisnttoo3ned,7if1fHerieonnt^pcouonlldescotifonassbyesstteoms s. TAhn<is* ln turn, wouic maxe it appear that expht million pouncs of asuescos is going into the operation. From the wording of the form, it would appear that this is exactly what the EPA wants However, another member was told that this in not what the EPA wante. ue suggests that if a factory takes in one Edllicm pounds of asbestos into the process that it should not report in total more than one tgLlLion pounds of asbestos. If be had 10 different emission points, he would divide the one million pounds of asbestos by 10 to give the "amount of pollutant." Again, their apparently has been a difference in interpretation from different Regional Offices of the EPA.
On page 3 of the report, under "Waiver of Compliance," it was stated that Sections 2a and 2b did not have to be corrpleted unless EPA specifically requests this information.
institute
or-: -safety
-health
At the February 16, 19 73 meeting, suggestions were made that the Institute consider the sponsoring of a seminar for members associated with plant operations. The Institute indicated it would be willing to sponsor such a seminar if suffi- . dent interest developed.
A question was raised as to whether this seminar would apply only to asbestos.
The Secretary indicated that such a seminar would apply to any field of interest
but it should be related to problems that can be tied into State and Federal
regulation. _ Among the ..tqpics suggested. for . a .seminar, were the following:.
..
Air sampling and asbestos concentration deterraination. The pulmonary function test and X-Ray.
Possible extension to include noise and heat stress. Cooperation between managecent and workers in meeting the
regulations. Asbestos bag opening machinery.
routes of cha Asbestos Study Committee Meeting
-5-
June l, 1973
The Secretary was directed to make up a list of subjects wnicn mignt interest the itecbership and to canvass the meters as regards their interest. In addition to the agenda itens to suggest to the M-erbership, it was suggested that the canvassing letter ask if an individual from that re^cr conrpany would attend,
where the meeting should be held, and when the meeting should be held. It was indicated that a meeting in the late fall would be desirable and such locations as Chicago, Detroit, Pittsburgh and Paramos were suggested.
Whan the Secretary has prepared a c\ueotionnaixe it will be submitted to Mr. Feierabend for his review prior to distribution to the Membership. The actual agenda will be drafted after the members have indicated their preference. The Question was raised as to whether outside speakers would be involved and it was suggested that we were not interested in a commercial pitch at the meeting. Johns-ilanville had indicated an interest in approaching such a seminar with the idea of promoting their HEAR (uigh Energy Air Filter) pollution control equip ment. It was suggested chat perhaps it eight be worthwhile to have outsiders sake presentations concerning asbestos bag epenin? equipment, pelletizing, collection, etc. This will have to be worked out at a future Committee meeting.
.
Drake and Clutch Emissions Cgnerated During Vehicle Operation
This particular study was run by Sendix Research Laboratories under sponsorship of the EPA. A paper was presented to the S.A.E. by Dr. N. Jacko and Jlr. R. DuCharma of Sendix, and !tr. J. Somers of the EPA. The actual report to the EPA is a massive document explainieg every test procedure and every method of collection used in the study. A technical paper was presented by these 3 entlfcren at the SA Meeting in Detroit in ''.ay, IS? 3. The study essent ally centers on how much asbestos is being put into the atmosphere from brake linings and clutch facings. As Dr. Jacko was in charge of this investigation he discussed the paper at our meeting. He advised that a condensed version appears in the magazine AUTOMOTIVE EDGIKEEf.INC. Among the points that Dr. Jacko made was that there were problems where a brake on one side was enclosed and the other brake was open to the regular atmosphere. Modifications had to be made involving cooling of the outside of the shroud so that there would not be too great a temperature difference from the left side to the right side. This was more of a problem with the disc brakes on the fronts. Actually with the necessary cooling, there vas hardly .any .difference -heQueen che drum brake -rears -side. c*ri>de.
Among the items discussed in the paper were hew much asbestos is used in friction materials. It is indicated that there are about 103 million pounds of asbestos in the friction materials which are used in the United States each year. There apparently are some differences of opinion as regards how much asbestos is involved but it generally falls in the 90-120 million pound range. Actually, the amount Subject to wear is about 66-2/32 of the actual lining that gets on to the brake (after grinding), tfhen asbestos is being used in brake linings it is discarded in one of three ways: It gets deposited on the surfaces of the.brake, such as on the caliper, and around the wheel cylinders. (This'll surface debris); Additional material is collected on the lining surfaces, in the rivet holes, and on the brake drum, (this is called sump debris) Additional material becomes airborne and is collected on weedbrane filters. (This is called airborne debris). It is this latter airborne debris that the researcheye arc seeking to quantify.
issed on tie sasples that vet* collected, t&m caerzixsriozs were char mssss.sss^. 99*71 of the asbestos la die brake lining is converted to other products, 'by extrapolating the data that they were able to develop on a pajsseegfiX ^ ^ researchers Indicate chat a total of 5060 pounds of asbestos is p
liinutes of the .Asbestos Study Committee Meeting
-6-
June 1, 1973
atmosphere. This airborne asbestos erissicr. is 3.T- of the total asbestos emitted from all automotive brake linings and clutch facings in the O.S.
A question arose as to what happens to the asbestos debris that drops out. Poes it eventually get into the atmosphere? It was indicated that based on the study of other materials that apparently there have been build-ups such as lead along the sides of turnpikes. This material apparently goes into the earth's surface and whether it is picked up again is dependent on other factors such as the proximity to streat*, etc.
A gentleman from Ford Motor Company was also to present a paper to the SAE meeting concerning asbestos particulate emissions into the atmosphere. Xo paper was available at this time. There were some questions concerning procedures and a source of data on the Ford paper, but in any event the paper indicated a lower total asbestos emission than the Eendix paper. These tvo papers should serve as source information when others are attempting to quantify the asbestos emi-tted into the atmosphere from brake linings and clutch facings.
CTT1ZR ITS 3
The topic of OSKA inspections and enforcement was brought up briefly and the t*triers indicated that no new actions had been taken by OSUA as regards enforce ment concerning the asbestos standards.
The Asbestos Information Association (AIA) is to put out a Compliance Manual concerning control practice. This is still preliminary and there is no advance copy available at this time.
******
There being no further business brought to the attention of the Committee, upon motion duly made and unanimously passed, it was
RESOLVED: to adjourn.
Adjourned; at 2:30 P.?J.
E. !!. Dris lane Secretary
Exhibit #J SX-224
Exhibits Minutes of the Asbestos Study Committee meeting dated 6/1/73. M. Jacko and D. E. Stone of Bendix were present.
Summary; The minutes from the previous minutes (AB--56) were read and accepted by the members. The members concluded that in order to meet the "true spirit of the OSHA regulations, manufacturers doing subsequent drilling, grinding or cutting of asbestos containing brake linings should use the care that OSHA suggests.* The membership concluded that the labels should state "Avoid creating dust."
Authentication; FMSI materials were sent to FHSI members, see Deposition of Edward Drislane, Hughes qt al. v. Johns-Manville et; .a.l, i August 23, 1982. Bendix was a member of the FMSI (Answers to Interrogatories, 91-80,000, Answer N4 41). Bendix received materials from the FMSI (Deposition of Eugene Rogers, Jaccme v. Manville, 1/5/84, p. 182).
Comments;
Asbestos Cement Fips Producers Association:
ANSWER:
Magnesia Insulation Man No.
tares issec
ANSWER:
G. American Industrial Hygiene Association: No.
ANSWER; ANSWER:
H. Brake Lining Manufacturers Association?
1* Brake Lining Manufacturer's Association.
2. The Bendix Corporation was a member from 1939 to 1949.
3. ALLIED-SIGNAL is unaware of any such documents.
I. Friction Materials Standards Institute, Inc.?
1- 588 Monroe Turnpike Monroer Connecticut 06468
2. 1949 to present.
3. ALLIED-SIGNAL employees may have received cooies of minutes of meetings of the FMSI, if any were prepared.
ANSWER:
J. Asbestos Brake Lining Manufacturers Institute; No.
ANSWER:
K. Quebec Asbestos Mining Association; No.
ANSWER:
L. Institute of Occupational and Environmental Health
of Quebec Asbestos Mining Association: No.
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